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Information for the NIH Extramural Grantee Community in the Event of a Lapse of Federal Government Funding

Posted on April 8, 2011 at 2:56pm

The continuing resolution (CR) to fund Federal government operations expires at midnight EDT on Friday, April 8, 2011. Given the uncertainties related to the National Institute of Health’s appropriation, we are planning for a potential lapse in Federal government funding. As part of the NIH plans, we are providing the following information to answer questions you may have on the impact such a lapse in appropriation will have on your grant/cooperative agreement or the availability of NIH’s systems and services.

RESUMING OPERATIONS

In the event of a lapse in funding, you are encouraged to stay tuned to the national media to determine when the Federal Government will resume operations. Depending on the length of a funding lapse, once NIH non-excepted staff are authorized to resume operations it will take time for full operations to be resumed. Depending on the length of the funding lapse, the eRA system may require at least one business day after operations resume. We ask for patience when trying to contact NIH staff once operations resume since there will be a backlog of information to process.

CONTACT WITH NIH STAFF

E-mail, Phone, Fax, and Postal Mail Contacts: In the event of a funding lapse, NIH extramural employees will be prohibited from working (remotely or in the office). Consequently, there will be no access to voice mail, e-mail, fax, or postal mail during this period. Mail requiring someone to sign/accept may not be received. All other postal mail, fax, and voice mail communications will not be acted upon until after operations resume. It is recommended that you delay sending such communications until after operations resume.

Help Desk Support: In the event of a funding lapse, all help desks, central e-mail boxes, and web ticketing systems for questions related to NIH grants policy and electronic grants systems may not be available, including the eRA Helpdesk and Grants Information Services.

SUBMISSION OF GRANT APPLICATIONS

In the event of a funding lapse, applicants are strongly encouraged not to submit paper or electronic grant applications to NIH during the period of the lapse. Adjustments to application submission dates that occur during a funding lapse will be announced once operations resume. For any applications submitted immediately prior to or during a funding lapse, here is what will likely happen.

a. For electronic submissions through Grants.gov: Grants.gov would be open and can accept electronic applications. However, applications would not be processed by NIH until the eRA Commons is back on-line.

b.Paper Submissions: Staff may not be available to receive paper applications during a funding lapse.

The safest course would be to wait to submit any application to NIH until after operations resume and a communication concerning adjusted submission dates is announced.

PEER REVIEW AND COUNCIL MEETINGS

Initial Peer Review Meetings: In the event of a funding lapse, the NIH would not be able to conduct initial peer review meetings – whether in-person or through teleconferences or other electronic media - during a lapse in Federal funding. Also during that time, the NIH staff would not be able to send or receive email messages, or update website information, and NIH computer systems that support review functions would not be operational. When operations resume, those meetings will be re-scheduled and the pending applications will be processed and reviewed as soon as possible.

Also, the results, including final impact scores and summary statements, of some peer review meetings that took place prior to the orderly shutdown of operations may not be available until operations resume. Therefore, applicants with applications going through the peer review process should stay tuned to the national news to determine when operations of the government resume, and then check the NIH website for information on any review meetings that may have been extended or re-scheduled. The results of meetings held prior to a potential funding lapse will be released as soon as possible after resumption of operations.

Individuals who had agreed to serve on NIH review panels (”study sections”) that were scheduled to meet during a funding lapse would not be able to access the Internet Assisted Review (IAR) site or other NIH web-based systems during that time. Reviewers who were scheduled to travel for a review meeting on a day when operations are down would not be able to board a plane or train, and will be sent instructions on how to handle their reservations. Reviewers who are attending an NIH review panel on the day of orderly shutdown would be able to change their travel plans and return home. Therefore, peer reviewers should stay tuned to the national news to determine when operations of the NIH will resume, and then check the NIH website for information on meetings that have been re-scheduled. As soon as possible after operations resume, the NIH Scientific Review Officer in charge of the review meeting will contact those reviewers with more detailed information.

Advisory Council Review: The NIH would not be able to conduct Advisory Council review meetings – whether in-person or through teleconferences or other electronic media - during a funding lapse. Also during that time, the NIH staff would not be able to send or receive email messages, or update website information, and NIH computer systems that support review functions will not be operational. Therefore, no applications would be processed for Council review or be taken to Council meetings during that time. When operations resume, those pending applications will be processed, and meetings will be re-scheduled as soon as possible.

Applicants with applications pending Council review during that time should check the NIH website for information after operations resume. Advisory Council members should stay tuned to the national news to determine when operations of the government will resume, and then check the NIH website for information on Council meetings that have been re-scheduled. As soon as possible after operations resume, the NIH Executive Secretary in charge of the Council meeting will contact those Council members with more detailed information.

AWARDED GRANTS

Currently Active Grant Awards: In the event of a funding lapse, all work and activities performed under currently active NIH grant awards may continue. However, see below for limits on performing many of the reporting requirements associated with NIH grant funding.

Progress Reports:

a.Electronically Submitted Progress Reports: For any SNAP progress reports and/or annual progress reports for multi-year funded grants due during the funding lapse, the eRA Commons would not be accessible. Users would need to wait until the eRA Commons is back on-line before these progress reports can be submitted.

b.Paper Submitted Progress Reports: No NIH staff would be available to receive paper progress reports. Therefore, institutions are encouraged to delay mailing all paper progress reports due during the funding lapse until after operations resume.

Notice of Awards (NoAs): No NIH grant awards will be processed in the event of a funding lapse. For any awards processed before a funding lapse that have an issue date during the funding lapse, the awards will not be sent to the grantee on the issue date. Once operations resume, all pending NoAs will be sent. This will not affect the start date nor the issue date of these awards; it just affects the date the award document is actually sent to the grantee and available for access in the eRA Commons. In the absence of actually receiving the NoA, institutions may use pre-award costs authority at their own risk.

No-cost Extension Notifications: The eRA Commons would not be accessible during a funding lapse. Further, no-cost extension notification cannot be submitted via the Commons once the expiration date of the grant has passed. For any grants due to expire during a funding lapse that plans to be given a no-cost extension, if the extension notification is not submitted before the eRA Commons is shutdown, then a paper notification to the IC will be required after operations resume.

General Access to eRA Commons and Other OER-Supported Systems: The eRA Commons will not be accessible in the event of a funding lapse. Therefore, no user would be able to access the Commons for viewing electronically submitted applications, accessing Internet Assisted Review, or processing such actions as Commons Registration, FSRs/FFRs, xTrain documents, Closeout documents, and/or FCOI notifications etc. Further there would be no ability to access Commons for query or other purposes. There also would be no access to the Interagency Edison or Electronic Council Books systems.

Prior Approval Requests and Other Communications: NIH extramural employees would have no access to voice mail, e-mail, fax, or postal mail in the event of a funding lapse. All prior approval requests and other communications would not be received until operations resume. It is recommended that you delay sending such communications until after operations resume.

Access to HHS Payment Management System (PMS): In the event of a funding lapse, the HHS PMS will be open; however, no Federal staff would be available to assist or process any requests. Therefore, drawdowns (payments) on accounts can be processed as long as no Federal staff action is required to finalize the payment. For most NIH grantees, this means drawdowns should be possible. However, if a particular grant is on a reimbursement basis for withdrawing funds or otherwise restricted, then these requests could not be processed until after Federal Government operations resume.

ANIMAL WELFARE

The Office of Laboratory Animal Welfare (OLAW) business processes are funded by annual appropriations and are not designated as excepted activities under the Antideficiency Act. No activities associated with the OLAW mission would continue in the event of a lapse of funding.

In the event of a funding lapse, assured institutions are encouraged to delay sending all Assurance documents, preliminary or final reports of noncompliance or IACUC suspensions as required under the Public Health Service Policy on Humane Care and Use of Laboratory Animals IV.F.3, or other correspondence due during the funding hiatus period until after operations resume. OLAW would extend deadlines for all reporting activities as necessary to compensate for the period of the lapse in funding and the unavailability of the website and OLAW operational support.

Institutions are reminded that their obligation under their Animal Welfare Assurance to ensure ongoing local support and oversight, and to address and correct all situations that affect animal welfare and compliance with the PHS Policy continues during this period.